Legal Documentation

Privacy Policy

The Heart Centered Leadership Institute

Last Updated: June, 2026

1. Introduction

The Heart Centered Leadership Institute (“THCLI,” “we,” “us,” “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and otherwise process your personal information through our website, applications, services, and other interactions with us.

Please read this Privacy Policy carefully. By accessing or using THCLI’s services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

2. Information We Collect

2.1 Information You Provide Directly

We collect information you voluntarily provide to us:

  • Contact Information: Name, email address, phone number, company name, job title
  • Account Information: Information provided when registering for services or creating an account
  • Assessment Data: Responses to THCLI’s Organizational Risk Assessment™
  • Communication Data: Content of emails, messages, or inquiries you send to us
  • Payment Information: Billing address and payment details (processed securely through Stripe; we do not store full credit card numbers)
  • Engagement Information: Information shared during diagnostic sessions, advisory work, or coaching engagements

2.2 Information Collected Automatically

When you visit our website or use our services, we automatically collect:

  • Device Information: Device type, browser type, operating system, IP address
  • Usage Information: Pages visited, time spent on pages, links clicked, referral source
  • Location Information: Approximate geographic location based on IP address (not precise)
  • Cookies and Tracking: Information stored via cookies, pixels, and similar tracking technologies

2.3 Information from Third Parties

We may receive information about you from:

  • Service Providers: Payment processors (Stripe), email service providers, analytics platforms (Google Analytics)
  • Business Partners: Referral partners or third parties who refer you to THCLI
  • Public Sources: Publicly available information used to verify or supplement data you provide

3. How We Use Your Information

3.1 Service Delivery

  • Providing executive advisory, coaching, diagnostic, and organizational consulting services
  • Delivering Risk Assessment results and diagnostic recommendations
  • Communicating about your engagement and next steps
  • Sending invoices, receipts, and service-related communications

3.2 Marketing and Outreach

  • Sending marketing emails and newsletters about our services (you can unsubscribe anytime)
  • Segmenting your email into relevant groups (e.g., risk-assessment-completers, leadership-operating-system-product) for targeted communications
  • Conducting email nurture sequences based on your engagement with our content
  • Inviting you to webinars, events, or new service offerings

3.3 Relationship Management

  • Understanding your needs and personalizing your experience
  • Improving communication and service delivery
  • Following up on inquiries or engagement opportunities
  • Managing client relationships and records

3.4 Legal and Compliance

  • Complying with legal obligations and regulatory requirements
  • Protecting against fraud, abuse, or security threats
  • Enforcing our Terms of Service and other agreements
  • Responding to lawful requests from authorities

3.5 Analytics and Service Improvement

  • Analyzing anonymized and aggregated data from engagements to improve our methodologies, develop new frameworks, and enhance service quality
  • Understanding which content and services are most valuable
  • Conducting research and developing new offerings
  • Measuring the effectiveness of our marketing
Important: This analysis does NOT identify individual clients and is used only to identify patterns and best practices across multiple engagements. Each client’s organizational information is kept strictly separate and confidential. We do not share any client’s specific information, findings, recommendations, or data with any other client.

4. Data Retention

We retain your personal information for as long as necessary to provide services and fulfill the purposes outlined in this Privacy Policy, and as necessary to comply with legal obligations.

Client Engagement Data

Retained for the duration of engagement plus as long as necessary for legal/tax compliance and service improvement

Email Subscribers

Retained until you unsubscribe or request deletion

Risk Assessment Responses

Retained as long as necessary for service improvement and follow-up marketing

Website Analytics

Retained for as long as necessary then aggregated/deleted

Payment Information

Retained per PCI compliance requirements (not stored by THCLI, stored by Stripe)

Unsubscribed Emails

Retained for 30 days to prevent accidental re-subscription and ensure compliance with email regulations. After 30 days, all records of your email are permanently deleted.

You can request deletion of your personal information at any time by contacting support@thcli.com. We will delete within 30 days, unless legal obligations require retention.

THCLI is responsible for ensuring all contractors, developers, and service providers comply with this deletion timeline and do not re-add unsubscribed emails to any system. If you believe your email was not deleted within 30 days, contact support@thcli.com.

5. How We Share Your Information

5.1 Service Providers

We share information with third-party service providers who assist us in operating our business:

  • Payment Processor: Stripe (for payment processing)
  • Analytics Provider: Google Analytics (for website analytics)
  • Contractors/Consultants: Team members or contractors assisting with service delivery
All service providers are contractually obligated to protect your data and use it only for the purposes we specify.

5.2 Separate Client Data

Each client’s organizational information, engagement data, and assessment responses are kept strictly separate and confidential. THCLI does not share any client’s specific information, findings, recommendations, or data with any other client. Client data is never pooled, combined, or cross-referenced with other clients’ information, except in anonymized, aggregated form used only for internal analytics and service improvement.

5.3 Legal Requirements

We may disclose your information if required by law, regulation, or legal process, or to protect our rights, privacy, safety, or property.

5.4 Business Transfers

If THCLI is involved in a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will provide notice (via email or website announcement) before your information becomes subject to a different privacy policy.

Your continued use of THCLI’s services after such notice constitutes acceptance of the new privacy policy. If you do not accept the new policy, you may request deletion of your personal information before the transfer.

5.5 With Your Consent

We may share your information with third parties when you explicitly consent to such sharing.

6. Data Security

THCLI implements reasonable technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction.

  • Encrypted data transmission (SSL/TLS)
  • Secure authentication and password protection
  • Access controls limiting employee access to personal data
  • Regular security assessments and updates
  • Confidentiality agreements with all service providers

However, no security system is impenetrable. We cannot guarantee absolute security of your information. You are responsible for maintaining the confidentiality of your passwords and account credentials.

7. Your Privacy Rights

7.1 Access and Portability

You have the right to request access to your personal information and receive a copy in a portable format (such as CSV or PDF). To request a data export, contact support@thcli.com with “Data Export Request” in the subject line. We will provide your data within 30 days at no cost. Data exports include all information we maintain about you, including engagement records, assessment responses, and contact information.

7.2 Correction and Deletion

You have the right to request correction of inaccurate information and deletion of your personal information (subject to legal retention requirements).

7.3 Opt-Out of Marketing

You can unsubscribe from marketing emails by clicking the unsubscribe link in any email or by contacting us directly. When you unsubscribe from marketing emails, your email address is immediately marked as “unsubscribe” in our system and you will receive no further marketing communications.

7.4 Withdrawal of Consent

If you consented to processing of your information, you can withdraw consent at any time.

7.5 Objection to Processing

You can object to certain types of data processing, such as automated decision-making. To exercise any of these rights, contact us at support@thcli.com with the specific right you’re requesting in the subject line. We will respond within 30 days.

8. International Data Transfers

THCLI operates from the United States. Your information may be transferred to, stored in, and processed in the United States or other countries where we or our service providers operate. These countries may have data protection laws that differ from your home country.

By providing information to THCLI, you consent to the transfer and processing of your information outside your home country.

9. California and US Privacy Rights (CCPA/CPRA) & GDPR Compliance

9.1 GDPR Compliance (European Union Residents)

THCLI complies with the General Data Protection Regulation (GDPR) for individuals in the European Union. All rights outlined in GDPR (including data access, correction, deletion, portability, and opt-out rights) are available to you. Standard Contractual Clauses are in place for transfers to non-GDPR jurisdictions.

9.2 CCPA/CPRA Compliance (California Residents)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

  • Right to Know: Request what personal information we collect and how we use it
  • Right to Delete: Request deletion of personal information (with certain exceptions)
  • Right to Correct: Request correction of inaccurate information
  • Right to Opt-Out: Opt-out of the “sale” or “sharing” of personal information for targeted advertising
  • Right to Limit Use: Limit our use of personal information to necessary purposes
  • Right to Non-Discrimination: We will not discriminate against you for exercising your rights

9.3 Does THCLI Sell or Share Personal Information?

No. THCLI does not sell personal information in exchange for money. THCLI may engage in “sharing” under CCPA for cross-context behavioral advertising (e.g., retargeting ads on other websites). If you wish to opt-out of this sharing, contact support@thcli.com.

To submit a GDPR, CCPA, or CPRA request, contact support@thcli.com with “Privacy Rights Request” in the subject line.

10. Cookies and Tracking Technologies

10.1 Cookies

We use cookies to enhance your experience on our website. Cookies are small files stored on your device that contain information about your browsing activity.

Types of cookies we use:

  • Essential Cookies: Required for website functionality
  • Analytics Cookies: Help us understand how visitors use our site
  • Marketing Cookies: Used for retargeting and advertising

10.2 Managing Cookies

You can control cookie settings through your browser preferences. Most browsers allow you to refuse cookies or alert you when cookies are being sent. Note that disabling cookies may affect website functionality.

10.3 Do Not Track

Some browsers include a “Do Not Track” feature. THCLI does not currently respond to DNT signals, but you can manage your privacy preferences through browser settings.

12. Children’s Privacy

THCLI’s services are not directed at children under 18 years old. We do not knowingly collect personal information from children. If we learn that we have collected information from a child under 18, we will promptly delete it. If you believe we have collected information from a child, contact support@thcli.com.

13. Contact Us

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or want to report a privacy concern, contact us at:

Email: support@thcli.com

Mailing Address: The Heart Centered Leadership Institute, Honolulu, HI

We will respond to privacy inquiries within 30 days.

14. Policy Changes

THCLI may update this Privacy Policy periodically. Material changes will be notified via email or a prominent notice on our website. Your continued use of THCLI’s services constitutes acceptance of the updated Privacy Policy.

This Privacy Policy is effective as of June 28, 2026 and has been customized for THCLI.

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